Basavaraj A. Hooli and Vindodini B. Hooli - Page 7




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          evidence.  See Watson v. Commissioner, T.C. Memo. 1988-29.  If no           
          other documentation is available, we may accept credible                    
          testimony of a taxpayer to substantiate a deduction.  Watson v.             
          Commissioner, supra.                                                        
               Moreover, expenses that are incurred before the commencement           
          of business operations constitute preopening or startup expenses            
          and are not deductible under section 162.  See Jackson v.                   
          Commissioner, 864 F.2d 1521, 1525-1526 (10th Cir. 1989), affg. 86           
          T.C. 492 (1986); Hardy v. Commissioner, 93 T.C. 684, 687-693                
          (1989); Goodwin v. Commissioner, 75 T.C. 424, 433 (1980), affd.             
          without published opinion 691 F.2d 490 (3d Cir. 1982).                      
               Generally, petitioner failed to introduce any reliable                 
          written substantiation for his claimed traveling expenses.                  
          Petitioner testified that he kept receipts that substantiated his           
          traveling expenses, but that the receipts were stolen.                      
          Petitioner’s testimony regarding his traveling expenses was                 
          generally vague and unconvincing.  At times he was almost                   
          hysterical.  Nevertheless, his presentation was at best a                   
          dramatic effort to explain his failure to provide substantiation            
          of his claimed travel expenses.  Petitioner also failed to                  
          demonstrate that he attempted to reconstruct these expenses.  He            
          did not present testimony of any other witness, except his wife,            
          to substantiate his own testimony.  Mrs. Hooli’s testimony was              
          brief and generally in the form of responses to her husband’s               
          leading questions.  We cannot give this unconvincing testimony              





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